Fragrance Allergen Labeling and the April 12 2026 List

Mark April 12, 2026 on your calendar if you sell a scented product in Canada. That's the reference date when List 1 fragrance allergens become mandatory, both on the Cosmetic Notification Form and on the product label itself. If you've been putting off checking your fragrance and essential oil formulas against an allergen list, this is the deadline that makes it non-optional.

What List 1 actually covers

List 1 is the original set of fragrance allergens that Health Canada requires disclosure for once they're present above certain thresholds. These aren't exotic synthetic additives, they're compounds that occur naturally in a huge range of essential oils that soap and skincare makers use every day. Limonene shows up in nearly every citrus oil. Linalool is in lavender, bergamot, and coriander. Citronellol and geraniol are common in rose and geranium oils. Eugenol is a major component of clove. Coumarin appears in tonka bean and some lavender chemotypes.

If your product has a fragrance blend or an essential oil in it, there's a real chance one or more of these is already present in your formula, whether you've been tracking it separately or not.

The concentration thresholds that trigger disclosure

Disclosure isn't triggered just by an allergen being present at all. It's triggered above specific thresholds, and the threshold depends on whether the product stays on the skin or gets rinsed off:

• Leave-on products (lotions, serums, leave-in conditioners): disclosure required above 0.001%, which is 10 ppm.
• Rinse-off products (soap, shampoo, cleansers): disclosure required above 0.01%, which is 100 ppm.

Those are low numbers. A fragrance oil used at a typical use rate can easily push an allergen like linalool past 10 ppm in a leave-on lotion, even when the fragrance itself is a small percentage of the total formula. This is exactly the kind of calculation that gets missed when a maker treats a fragrance blend as one line item instead of breaking it down into its actual components.

Why the math requires expanding your blend

If you buy a fragrance oil from a supplier and it's listed as 2% of your formula, that 2% is not the allergen concentration, it's the fragrance blend concentration. You need the supplier's breakdown of what's inside that blend, then multiply each component's percentage by your use level to get the real concentration in the finished product.

An example: your supplier's fragrance blend is 15% linalool by weight, and you're using that blend at 2% in your finished lotion. The actual linalool concentration in your product is 15% times 2%, which works out to 0.3%, or 3,000 ppm. That's dramatically above the 10 ppm leave-on threshold, so it needs disclosure even though "2% fragrance" sounds small on its own.

What changes on the CNF and the label

Once List 1 becomes mandatory on April 12, 2026, allergens present above threshold need to appear:

1. On the Cosmetic Notification Form itself, as part of your ingredient disclosure to Health Canada.
2. On the product label, typically within or alongside the ingredient list, so consumers with known sensitivities can see them.

This is layered on top of your normal INCI-based ingredient list, not a replacement for it. You're not choosing between the standard ingredient declaration and allergen disclosure, you need both to line up correctly.

List 2 is coming right behind it

List 1 isn't the end of this. An expanded set of allergens, List 2, aligned with international lists, becomes mandatory on August 1, 2026. If you're rebuilding your fragrance documentation for the April deadline, it's worth pulling your supplier data for the full expanded list at the same time rather than doing this exercise twice in one year.

A short checklist before April 12

• Get full component breakdowns from every fragrance and essential oil supplier you use, not just a top-note summary.
• Calculate actual finished-product concentration for each named allergen, not the blend percentage.
• Separate your leave-on and rinse-off products since they have different thresholds.
• Update label artwork and CNF entries together so they stay in sync.

Cosmetic Comply's ingredient matching handles the blend expansion step automatically, taking a supplier's fragrance percentages and carrying them through to real finished-product concentrations, which is usually where this kind of allergen math goes wrong when it's done by hand.